We have translated 7 more CRA interpretations
17 February 2025 - 11:48pm
Email this ContentWe have translated a CRA interpretation released last week and a further 6 CRA interpretations released in January of 2001. Their descriptors and links appear below.
These are additions to our set of 3,110 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 24 years of releases of such items by the Directorate. These translations are subject to our paywall (applicable after the 5th of each month).
| Bundle Date | Translated severed letter | Summaries under | Summary descriptor |
|---|---|---|---|
| 2025-02-12 | 11 December 2024 External T.I. 2024-1039101E5 F - Vertical amalgamation & former paragraph 84.1(2)(e) | Income Tax Act - Section 84.1 - Subsection 84.1(2) - Paragraph 84.1(2)(e) | s. 87(2)(j.6) continuity rule does not remediate the adverse consequences under the old intergenerational transfer rules of vertically amalgamating the subject corp |
| Income Tax Act - Section 87 - Subsection 87(2) - Paragraph 87(2)(j.6) | s. 87(2)(j.6) does not apply for purposes of the “old” s. 84.1(2)(e) intergenerational transfer rules | ||
| 2001-02-02 | 23 October 2000 Internal T.I. 2000-0027477 F - ALLOCATION DE RETRAITE | Income Tax Act - Section 248 - Subsection 248(1) - Retiring Allowance | exclusion for replacement employment at an alleged affiliated employer was not applied |
| 2001-01-19 | 5 January 2001 External T.I. 2000-0010905 F - Valuation - Freeze shares | General Concepts - Fair Market Value - Shares | requirement to seek consent detracts to retraction detracts from FMV of freeze preferred shares |
| Income Tax Act - Section 86 - Subsection 86(1) | right to retract freeze preferred shares must not be fettered | ||
| 4 January 2001 External T.I. 2000-0047605 F - FRAIS DE DIVERTISSEMENT | Income Tax Act - Section 67.1 - Subsection 67.1(1) | attending shows in order to identity artist recruits might be entertainment | |
| Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(a) | s. 67.1(2)(a) exception unavailable for tickets to shows attended to recruit artists | ||
| 10 January 2001 External T.I. 2000-0049585 F - DEDUCTIBILITE DES INTERETS | Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(c) - Subparagraph 20(1)(c)(i) | annual payment cap on interest until maturity did not preclude deductibility | |
| 5 January 2001 Internal T.I. 2000-0053767 F - IT-92R2 Paragraphe 1 | Income Tax Act - Section 9 - Timing | progress method per IT-92R2 could be used by supplier of kitchen equipment if installed by it pursuant to the building construction plans and title thereto thereupon vested in the building owner | |
| Income Tax Act - Section 12 - Subsection 12(1) - Paragraph 12(1)(b) | construction holdbacks not receivable until approved for release | ||
| 2001-01-05 | 19 December 2000 External T.I. 2000-0035685 F - RPA TRANSFER AU DECES | Income Tax Act - Section 147.3 - Subsection 147.3(7) | deceased member can have had more than one qualifying spouse or partner |